G.R. No. 185979 . March 16, 2016.
Bangko Sentral ng Pilipinas, Petitioner, vs. Vicente Jose Campa, Jr., Miriam M. Campa, Maria Antonia C. Ortigas, Maria Teresa C. Arevalo, Maria Nieves C. Alvarez, Marian M. Campa and Balbino Jose Campa, Respondents.

FACTS

The case originated from a loan obtained by Bankwise, Inc. from petitioner Bangko Sentral ng Pilipinas (BSP) under a Special Liquidity Facility (SLF). As required by BSP, Bankwise mortgaged real properties belonging to third parties, including respondents Vicente Jose Campa, Jr., et al. When Bankwise defaulted, BSP extrajudicially foreclosed the mortgaged properties, including those of respondents, and purchased them at public auction.
Eduardo Aliño, another third-party mortgagor and a stockholder of VR Holdings (which was involved with Bankwise), filed a complaint (Commercial Case No. 06-114866) against BSP and Bankwise for specific performance, novation of contracts, and damages. Aliño alleged that BSP had agreed to settle Bankwise’s obligation via a dacion en pago arrangement, accepting properties from Bankwise’s former owners, and that the foreclosure of his properties was done in disregard of this arrangement. Another third-party mortgagor, Haru Gen Beach Resort and Hotel Corporation, filed a motion to intervene, which the Regional Trial Court (RTC) denied, ruling its cause of action should be a separate proceeding.
Subsequently, respondents filed a Motion for Leave to Intervene and Admit their Complaint-in-Intervention. They asserted a legal interest as registered owners of the mortgaged properties, which they accommodated for Bankwise based on assurances of no foreclosure risk, and realleged the causes of action in Aliño’s complaint. The RTC granted their motion. BSP filed a petition for certiorari with the Court of Appeals, arguing grave abuse of discretion. The Court of Appeals affirmed the RTC order and denied BSP’s motion for reconsideration.
BSP elevated the case to the Supreme Court, contending that respondents failed to meet the requisites for intervention and that, since Aliño’s suit was a derivative action filed as a stockholder of VR Holdings, non-stockholder respondents could have no legal interest in the litigation. BSP also argued that respondents should be treated similarly to Haru Gen, whose intervention was denied.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in granting respondents’ Motion for Leave to Intervene in Commercial Case No. 06-114866.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ resolutions. The RTC did not commit grave abuse of discretion in allowing the intervention.
The Court held that the requisites for intervention under Section 1, Rule 19 of the Rules of Court were satisfied. Respondents have a legal interest in the matter of litigation because they are the registered owners of the foreclosed properties, which are the direct subject of Aliño’s complaint seeking to nullify the foreclosure based on the alleged dacion en pago agreement. Their interest is actual, material, direct, and immediate, as any judgment declaring the foreclosure improper would directly benefit them by potentially restoring their titles.
The Court rejected BSP’s argument that the case is a derivative suit barring intervention by non-stockholders. It found that Aliño’s complaint was not a derivative suit. A derivative suit is filed by a shareholder to enforce a corporate cause of action. Here, Aliño sued in his personal capacity as a mortgagor to protect his own property rights, not to vindicate a right of VR Holdings or Bankwise. The causes of action (specific performance, novation) and the reliefs sought (nullification of foreclosure, return of properties) were personal to the mortgagors. Therefore, the nature of the suit did not preclude intervention by other similarly situated third-party mortgagors.
Furthermore, the Court found no grave abuse of discretion in treating respondents differently from Haru Gen. The denial of Haru Gen’s intervention was based on the trial court’s discretion at that time, considering Haru Gen’s specific allegations (e.g., lack of consideration, unauthorized mortgage) which it deemed proper for a separate proceeding. The allowance of respondents’ intervention, who realleged the main plaintiff’s theory (dacion en pago), was a valid exercise of judicial discretion to avoid multiplicity of suits and ensure a complete resolution of all related claims concerning the same foreclosure issue.
Thus, the intervention was proper, and the RTC’s order was upheld.